EFTA01810331.pdf

Case 9:08-cv-80736-KAM Document 138 Entered on FLSD Docket 01/06/2012 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. RESPONDENT'S SECOND MOTION FOR ENLARGEMENT OF TIME TO FILE REPLIES AND RESPONSES TO PETITIONERS' RESPONSES AND MOTIONS FILED ON DECEMBER 5, 2011 Respondent, by and through its undersigned counsel, files its Second Motion for Enlargement of Time to File Replies and Responses to Petitioners' Responses and Motions filed on December 5, 2011, and state: 1. On December 5, 2011, petitioners filed their Response to Government's Sealed Motion to Dismiss for Lack of Subject Matter Jurisdiction (D.E. 127); Response to Government's Sealed Motion to Stay (D.E. 129); Protective Motion for Remedies (D.E. 128); and Protective Motion to Compel (D.E. 130). Respondent's replies to petitioners' two responses were due on December 15, 2011, while responses to petitioners' two motions were due on December 22, 2011. 2. On December 15, 2011, respondents moved for an enlargement of time, up to and including January 6, 2012, to file the two responses and two replies. The Court granted respondent's motion on December 15, 2011. D.E. 137. EFTA_R1_00172147 EFTA01810331 Case 9:08-cv-80736-KAM Document 138 Entered on FLSD Docket 01/06/2012 Page 2 of 3 3. Respondent has begun preparing its responses and replies. However, Assistant U.S. Attorney has been occupied for the past several weeks in preparing for an evidentiary hearing scheduled for January 24, 2012, for a motion filed by an incarcerated individual under 28 U.S.C. § 2255. Assistant U.S. Attorney will be starting a civil trial on Tuesday, January 17, 2012, at 10:00 a.m. M.C. v. United States, Case No. 11-20216- CIV-UNGARO (S.D.Fla.). The responses and replies will be prepared by Assistant U.S. Attorney with limited assistance from AUSAs and. 4. On January 5, 2012, the undersigned contacted petitioners' counsel to determine their position on the instant motion. Petitioners' counsel graciously did not oppose the instant motion. WHEREFORE, respondent respectfully requests a second enlargement of time, up to and including January 24, 2012, to file its reply to petitioners' response to respondent's sealed motion to dismiss for lack ofjurisdiction (D.E. 127), and respondent's sealed motion to stay (D.E. 129); and to file its response to petitioners' protective motion for remedies (D.E. 128), and protective motion to compel (D.E. 130). DATED: January 6, 2012 Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: s/ Assistant U.S. Attorney 99 N.E. 4d, Street Miami, Florida 33132 Fax: 2 EFTA_R1_00172148 EFTA01810332 Case 9:08-cv-80736-KAM Document 138 Entered on FLSD Docket 01/06/2012 Page 3 of 3 E-mail: Attorney for Respondent CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 6, 2012, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. s/ Assistant U.S. Attorney SERVICE LIST Jane Does I and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale Florida 33301 Fax: E-mail Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake Ci , Utah 84112 Fax: E-mail: Attorneys for Jane Doe # 1 and Jane Doe # 2 3 EFTA_R1_00172149 EFTA01810333